Case Summary (G.R. No. 177356)
The Facts of the Case
On June 10, 2003, at approximately 3:00 a.m., Richard Avila Roda, an Assistant Manager at the Nognog Videoke Restaurant, witnessed a violent assault taking place outside the establishment. He recognized three of the assailants—Amodia, Marino, and Lo-oc—as regular customers. These individuals, alongside four unidentified accomplices, were seen mauling the victim, Jaime Bartina. During the attack, Roda observed Lo-oc restraining the victim while Marino and Amodia inflicted physical harm. After the assault, the accused-appellants returned to the restaurant and consumed alcohol, while Roda refrained from reporting the incident due to threats made against him by the accused. Later that same day, the victim was found injured and subsequently passed away.
Charges and Defense
Roda reported the assault to the police two days later, which led to the filing of an Information against the accused-appellants for murder, citing evident premeditation and treachery, taking advantage of superior strength. The accused-appellants pleaded not guilty and sought to establish alibis. Lo-oc maintained that he had been drinking at another bar during the time of the incident and only came across the victim after the attack had occurred. Amodia and Marino corroborated his account, denying participation in the crime.
The Ruling of the Regional Trial Court
On August 24, 2005, the Regional Trial Court found all three accused guilty of murder, sentencing Amodia to a lighter penalty due to being a minor at the time of the offense, while Marino and Lo-oc received the penalty of reclusion perpetua. The court ordered the accused to pay damages to the heirs of the victim. The verdict was grounded on the credible eyewitness testimony provided by Roda, which was deemed reliable despite the defense's assertions.
The Appeal and Court of Appeals' Rationale
The case was subsequently appealed to the Court of Appeals. In its decision on January 23, 2007, the appellate court upheld the trial court's ruling, emphasizing the credibility of the eyewitness testimony, which had gone unchallenged by substantial evidence from the defense. The appeals court dismissed the argument surrounding the non-flight of the accused, asserting that the presence of the accused at the scene did not undermine the eyewitness account.
The Supreme Court's Findings
The Supreme Court partially granted the appeal. It agreed with the trial court's credibility assessment of the witness but found that the prosecution did not adequately establish the qualifying circumstance of "abuse of superior strength." Thus, while the accused were guilty of homicide rather than murder, the penalties were adjusted. The Supreme Court confirmed c
...continue readingCase Syllabus (G.R. No. 177356)
The Case
- This case is an appeal from the January 23, 2007 Decision of the Court of Appeals (CA) in CA-G.R. CR-H.C. No. 01628.
- The CA Decision affirmed the August 24, 2005 Decision of the Quezon City Regional Trial Court (RTC), Branch 89, which found accused-appellants Johbert Amodia, Mario Marino, and Roy Lo-oc guilty of murder.
The Facts
- On June 10, 2003, at approximately 3:00 a.m., Richard Avila Roda, an Assistant Manager at Nognog Videoke Restaurant in Quezon City, witnessed an assault outside the establishment.
- Roda observed seven individuals attacking a man, later identified as Jaime Bartina, with three of the assailants being the accused-appellants.
- Lo-oc held the victim while Marino and Amodia alternated in beating him. One accomplice brandished a knife and threatened Roda.
- The victim fell to the ground, bleeding from a head injury. Roda intervened, urging the attackers to stop but was initially intimidated into silence.
- Following the assault, Roda later discovered the victim's body still at the scene and learned that Bartina had been taken to the hospital, where he died later that day.
- Roda reported the incident to the police two days post-assault, leading to the filing of murder charges against the accused-appellants.
The Information Filed
- The Information charged the accused-appellants with murder, specifying their c